2014-05-30-fa28-interim-consolidated-industry-submission-c091da9545fc31c2.pdf

This document is an interim consolidated industry submission regarding the draft schedule for implementing Section 21 of the Air Quality Act. It outlines industry positions on minimum emission values, compliance timeframes, monitoring approaches, and the management of fugitive emissions and upset conditions, emphasizing the need for standards to be based on the Best Practicable Environmental Option (BPEO) principle within the South African context.

• Industry argues that minimum emission values for the same pollutant may differ across activities because the available abatement technology varies by process. They advocate for the Best Practicable Environmental Option (BPEO) principle, which incorporates Best Available Technology/Technique (BAT), practicability (informed by cost-benefit analyses), and environmental options.
• Industry proposes specific definitions and timelines for plant compliance: 'New Plant' refers to any plant operating after the notice takes effect, with compliance dates incorporated into licenses. 'Existing Plant' refers to those operating before the notice, with a proposed maximum compliance window of 8 years, citing capital project timeframes and the global economic crisis.
• The proposed compliance monitoring approach requires periodic emission testing using methods listed in the Schedule or other validated international methods. Testing must occur under normal operating conditions and be normalized to 273K, 101.3 kPa, Dry gas. For continuous monitoring, the averaging period for compliance is suggested as 30 days or as specified in the license.
• Industry suggests that fugitive emissions be managed through site-specific fugitive management plans, which should be handled via the Atmospheric Emission Licence process for activities that may impact human health.
• The submission proposes that emission standards should not apply during scheduled maintenance (start-up, shutdown) or 'upset conditions,' defined as any unavoidable failure of process or air pollution control equipment. A management plan is recommended to address upset conditions that significantly exceed emission values.
• Industry recommends postponing the inclusion of standards for additional metals and dioxins to the next setting process, arguing that the current focus should remain on priority pollutants and that adding them now would bypass proper BPEO consideration.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa28-interim-consolidated-industry-submission-c091da9545fc31c2.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA28-Interim-Consolidated-Industry-Submission.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa28-interim-consolidated-industry-submission-c091da9545fc31c2.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA28-Interim-Consolidated-Industry-Submission.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=2014-05-30-fa28-interim-consolidated-industry-submission-c091da9545fc31c2.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA28-Interim-Consolidated-Industry-Submission.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrightsnd20140530fa28interimconsolidatedindustrysubmissionc091da9545fc31c2pdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa28-interim-consolidated-industry-submission-c091da9545fc31c2.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA28-Interim-Consolidated-Industry-Submission.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }